(1.) THIS appeal is filed by the assessee challenging the impugned order of the Ld. CIT(A) -II, Pune dated 12 -12 -2012 for the A.Y. 2004 -05. The assessee has filed the revised grounds in place of original grounds which are taken on record as under:
(2.) THE Ld. CIT(A) erred on facts and in law in holding that the proceedings u/s. 147 initiated against the appellant are legally valid.
(3.) THE Ld. CIT(A) erred on facts and in law in confirming the action of the AO in applying the provisions of Sec. 189 for passing the impugned assessment order without giving a finding that conditions for doing so as laid down in Sec. 189 have been fulfilled.